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Comment Letter to CMMI Showcases Recommendations to Improve the OCF

By: Aaron Lyss, MBA; Stephen M. Schleicher, MD, MBA

OneOncology submitted its comments to The Centers for Medicare and Medicaid Services (CMS) regarding the Oncology Care First (OCF) Request for Information (RFI). In the letter, OneOncology emphasized support for the Center for Medicare and Medicaid Innovation’s (CMMI) payment reform efforts and for their transparency throughout the rulemaking process.

While OneOncology’s comment letter puts forth detailed recommendations addressing risk arrangements, monthly management payments, performance-based payments and practice redesign, below we’ve highlighted our recommendations for the latter two.

Performance Based Payments

Physicians largely have no control over the price of drugs, rather they can only control whether treatment decisions are concordant with current standards of care and concordant with the goals of care of individual patients and their caregivers. Therefore, we propose that measuring clinical pathway adherence is a better mechanism for measuring high-value care, since adherence to clinical pathways implicitly minimizes inappropriate drug utilization and is largely within a medical oncologist’s control. Read more here.

Practice Redesign

CMMI should allow practices maximum flexibility in how the agency implements the Practice Redesign Activities in order to provide physicians and care teams with the opportunity for care delivery innovation that best serves the needs of their patients. CMMI should also try to reduce the burden of clinical data reporting for practices participating in the model.

Since the OCM began, remarkable practice transformation in the cancer care delivery systems has occurred, in part, driven by the use of Monthly Enhanced Oncology Services (MEOS) Payments to hire staff and invest in technology to make care delivery more efficient and better coordinated.

Therefore, CMMI should take care to articulate that Practice Redesign Activities are intended to for guidance that practices have the flexibility to best meet CMMI’s goals.

Next-Generation Value Models

Moving our payments systems from volume to value requires collaboration and transparency. OneOncology’s network of over 250 physicians, many of whom participate in the OCM and commercial payer value-based arrangements, appreciates CMMI’s dedication to building next-generation payment models and looks forward to further collaboration to improve the lives of everyone living with cancer.